Does selling nongambling products to a hotel connected to a casino require any approvals?

Q: My company sells products to a hotel that is connected to a casino. The products have nothing to do with gambling and are solely for the hotel’s use. Do I have to receive any approvals or gaming licenses for these sales?

A: If the hotel or another nongaming establishment is considered part of the overall casino complex, then a supplier’s license issued by the gaming regulators is very likely required. However, there are many potential exceptions and exemptions available for companies that provide products that do not affect gambling activity.

Most jurisdictions have separate licenses for gaming products and nongaming products, with the nongaming licensure process being less intrusive than the gaming license process. Some jurisdictions, such as Ohio, do not require any licensure for companies that supply nongaming goods, but do retain the right to call the company forward for licensing on a discretionary basis. Others, such as Michigan, have different levels of nongaming approvals depending on the total amount of business conducted in a year. If the amount of business conducted in a 12-month period is nominal, then the supplier may qualify for an automatic or discretionary exemption that requires only limited filings.

As there is considerable variation in how each jurisdiction handles nongaming suppliers, it is important to work closely with your casino contact to ensure that you receive the proper approvals before supplying products. The jurisdiction list provided on this site also provides an overview of nongaming licensing thresholds in several jurisdictions.

Gaming industry advisor Regulatory Management Counselors, P.C. authored this article. Visit the Gaming Advisors section of this website to find out more about gaming licensing and compliance advisors.